The Langstane Group. Legionella Management Policy

Transcription

1 The Langstane Group Legionella Management Policy SMT approval date 24 th August 2017 Committee / sub committee Board of Management Approval date 2 nd October 2017 Implementation date 1 st November 2017 Review date November 2020 Version Version 1 Page 1 of 10

2 Version Date of approval Changes Version 1 2 nd October 2017 First issue Page 2 of 10

3 1. Introduction Legionellosis is the collective name given to the pneumonia like illnesses caused by the legionella bacteria and includes the more serious and well known Legionnaire s disease, but also the similar but less well known conditions of Pontiac fever and Lochgoilhead fever. There are around 400 known cases of Legionnaires disease each year in the UK but experts believe the real figure may be much higher, as healthy people generally don t report the illness to their doctor. People of any age may get Legionnaires disease, but the illness most often affects middle-aged and older persons, particularly those who smoke or have chronic lung disease and heavy drinkers. Also at increased risk are those with immune systems suppressed by diseases such as cancer, kidney failure requiring dialysis, diabetes or AIDs. Anyone taking medication that suppresses the immune system is also at increased risk. All man-made hot and cold water systems are likely to provide an environment where legionella can grow. Where conditions are favourable (ie suitable growth temperature range, water droplets (aerosol) produced and dispersed, water stored and recirculated, some food for the bacteria such as rust, sludge, scale, biofilm) then the bacteria may multiply, increasing the risk of exposure. The infection in humans is caused by breathing in contaminated air-borne water droplets such as water sprays from shower heads which contain the bacteria. 2. Policy Statement This policy sets out how Langstane Housing Association will comply with its duties in respect of the effective management of water systems to ensure the health and safety of tenants, staff and the general public by minimising the risk posed by legionella. This policy covers both domestic and commercial properties. 3. Objectives The objectives of this policy are to set out a clear approach to assessing, controlling and monitoring the risk of legionella within water systems which are under the control of the Association. 4. Links to other policies This policy should be read in conjunction with: The Association s Health & Safety Policy Voids Policy Planned & Cyclical Maintenance Policy Page 3 of 10

4 5. Legal, statutory and regulatory requirements There is no legislation specific to Legionella, but the following do place specific duties on LHA with regards to the control of Legionella: The Health and Safety at Work Act As a landlord, Langstane Housing Association has a duty under the Health and Safety at Work Act 1974 to ensure the health and safety of tenants by keeping properties safe and free from health hazards, including legionella. The Control of Substances Hazardous to Health Regulations 2002 (COSHH) - Legionella pneumophila is classed as a biological agent by the Health and Safety Executive (HSE) and is listed as a Class 2 hazard under the COSSH Regulations Under these Regulations LHA has a statutory duty to: Identify and assess sources of risk If appropriate, prepare a written scheme for preventing or controlling the risk Implement, manage and monitor precautions Keep records of precautions Appoint a competent person with sufficient authority and knowledge of the installation to help take the measures needed to comply with the law. HSE Approved Code of Practice (ACOP) The Control of Legionella bacteria in water systems The HSE ACOP is not an Act or Regulations but does have legal status. If there were to be an outbreak of legionella at an Association property, it would be essential for the Association to show that it had followed the relevant provisions of the ACOP, or that it had complied with the law in some other way. The ACOP is intended to offer practical advice on how to comply with the law the guidance is not compulsory but it does illustrate good practice and HSE inspectors seeking to secure compliance with the law may use this guidance as a point of reference. 6. Duty Holders and Nominated competent persons Duty Holders Chief Executive - Overall duty to ensure the organisation has sufficient resources and systems in place to achieve and maintain statutory compliance. Director of Asset Management/ Director of Housing and Social Justice - Overall responsibility for delivering statutory compliance. Asset Manager/Property Services Manager - Responsible for delivery of legionella management plan, reviewing policy & procedures regularly and for associated budgets. Page 4 of 10

5 Senior Technical Officer/ Team Leader Property Services - Responsible for day to day delivery, maintaining the compliance register & compliance with the ACOP. Gas servicing contractor - Responsible for servicing & remedial works to heating systems (all systems) & thermostatic mixing valves (domestic only) Nominated Competent Persons The Association will employ a suitably qualified consultant/contractor to act as a nominated competent person. Legionella consultants/contractors must comply with the following requirements: Membership of a recognised body such as the Legionella Control Association Public Liability, Employers and Professional Indemnity insurance is in date and complies with our approved consultants/contractors requirements Employees hold sufficient qualifications and maintain training records 7. Risk assessments In accordance with the COSSH Regulations 2002, and good practice set out in the HSE ACOP, the Association has a duty to assess the risk from exposure to legionella to ensure the health and safety of tenants. However, the Association has around 2,800 domestic properties in ownership or management. Carrying out full risk assessments for every property would not be practical and a proportionate approach will taken as set out below. Initially, an in-house assessment will be made for properties to group them into the following risk categories: Low risk An example of a low risk property might be general needs domestic premises, including houses, flats and maisonettes where the water systems are small-scale domestic type with high turnover, ie in daily use with cold water gravityfed tank to a conventional copper storage cylinder, or mains water system with a combination boiler. Medium risk Examples of medium risk properties might be shared premises (commercial, HMO or hostel accommodation for example) with cold water system fed via stored water and/or hot water via calorifiers with pumped distribution or mains water system, or domestic premises with some form of shared water storage. Properties with equipment such as a fire sprinkler systems will also be classed as medium risk. High risk Examples of high risk properties might be healthcare or commercial properties with cooling towers or air conditioning systems. Page 5 of 10

6 This initial assessment will be based on written or drawn information about properties along with site visits to a representative proportion of properties. The stock condition surveyor undertakes a rolling programme of property inspections and, after the initial risk assessments are complete the surveyor will continue to gather information on water systems during these visits. Where the information gathered during a visit differs from that used to carry out the initial risk assessment for the property, the risk assessment will be reviewed. In addition to the risk categories detailed above, the Association has identified an increased level of risk associated with void properties which remain void for longer than 7 days. The approach to reducing the risk attached to void properties is set out in Section Controlling the risks For each risk category, a written scheme of control will be prepared to ensure the ongoing safe control of the water systems. Low risk properties where properties have been identified as low risk, the ongoing control measures will include: Avoidance of debris entering water systems systems with stored cold water to be checked to ensure tanks have tight fitting lids Control parameters for the system to be checked, for instance temperature settings for hot water tanks Redundant pipework identified and removed Advice provided to new tenants on maintaining safe water systems Advice provided to existing tenants via the LHA website and periodically in tenant newsletter For low risk properties, the in-house risk assessment will be reviewed every 2 years or where there is a significant change to the property (for instance the installation of a new heating system). Medium and high risk properties a specialist water quality consultant will be appointed to carry out detailed, site specific risk assessments for all medium and high risk properties and to prepare site specific written schemes of control. The site specific written schemes of control will include: Details of the water systems including up to date plans or schematics Details of who is responsible for managing the property and carrying out the maintenance work Details of the safe and correct operation of the relevant systems Details of what control methods and precautionary measures are to be taken, and by whom Page 6 of 10

7 Details of the frequency and type of checks that re required, and who will undertake these The written scheme will be incorporated into a site log book which is to be available in the property and is to be kept up to date at all times. All persons with any duty under the written scheme, including staff and contractors, are to be advised of the presence and location of the log book. For medium and high risk properties, risk assessments will be reviewed annually or where there is a significant change to the property. Void properties legionella bacteria will begin to multiply if left undisturbed in stagnant water for too long. In void properties the Association will: Short term voids (less than three weeks) Ensure water outlets (taps, wc, whb, shower etc) are run weekly Remove the shower head and disinfect or replace with new prior to the tenant moving in. Flush the system through completely immediately prior to the new tenants moving in if the property has been void for longer than 2 weeks. Long terms voids (more than three weeks) Where a property will be void for longer than three weeks, it will usually be more cost-effective to drain down the water system. Immediately before letting, a specialist contractor agreed with Property Services will charge up the system, calculate the system capacity, chlorinate/disinfect accordingly and carry out a PH test to ensure levels are safe. This must be carried out in line with BS EN 806. If the decision is taken not to drain the system down, then a weekly flushing regime must be strictly followed. For all voids During void works, if dead legs are identified in the plumbing system they will be removed Cold water storage tanks will be checked to ensure lids are securely fitted. Missing or damaged lids will be replaced. System controls will be checked to ensure they meet safe limits. 9. Monitoring and recording The Senior Technical Officer / Team Leader Property Services will ensure that all routine measures detailed in the written schemes are implemented in accordance Page 7 of 10

8 with the required time intervals and that accurate, complete and up to date records are kept. Specific controls for at risk properties will be detailed in the log book for that property along with a record of when measures were last carried out and are next due. Controls may include any of the following measures to prevent the growth of legionella within the water system: Carrying out maintenance or remedial works Disinfection of the system Keeping water cisterns covered, insulated, clean and free from debris Ensuring water cannot stagnate anywhere in the system eg removing redundant pipe work, running taps / showers in unoccupied rooms Insulating pipework Maintaining the correct temperature at the hot water cylinder Advising personnel working on the system about the risks and how to minimise them Advising tenants about the risks, the control measures and precautions that can be taken to minimise them In line with best practice legionella records will be retained for a minimum of five years. The Director of Asset Management / Asset Manager will carry out periodic audits of legionella processes to ensure measures are being carried out timeously and records are being kept up to date. 10. Contractors The Association will ensure that any appointed specialist water quality consultants / contractors are competent to carry out their duties, which may include: Provision of detailed risk assessments and written schemes for the prevention and control of water borne infections including Legionella Plumbing and engineering works on air conditioning systems and hot / cold water systems Cleaning of water systems and chemical treatment of water supplies Bacterial and chemical water testing and analysis Contractors / consultants must be on the Association s approved contractors list and must be registered with the Legionella Control Association. The work of contractors / consultants will be regularly reviewed to ensure it meets the standards expected. Contractors / consultants who do not produce work to an acceptable standard are to be removed from the approved contractors list and may not be used for further works. Page 8 of 10

9 11. Legionella awareness for tenants For risk levels to remain low in properties it is essential that tenants are aware of the need to have a regular turnover of water from outlets such as taps and shower heads. Risk levels will increase in properties that are left empty for long periods. New tenants will be provided with a legionella awareness leaflet in their tenancy pack. The leaflet will be made available to existing tenants through the Association s website and legionella advice will also be communicated through other forums such as the tenant newsletter. High risk tenants (older tenants and those with existing medical conditions) who have to leave their properties for long periods of time (for instance to go in to hospital) will be advised to contact the Association for advice on reducing the risk when they return to their home. 12. Actions to be taken in the event of an outbreak An outbreak of legionella is defined as two or more cases where the onset of illness is closely linked in time and where there is evidence of a common source of infection. The investigation into an outbreak is led by the relevant Local Authority s nominated Proper Officer (usually a Consultant in Public Health Medicine). The Proper Officer will declare the outbreak and invoke an Outbreak Committee with responsibility for protecting public health and preventing further infection. The Health and Safety Executive may be involved in the investigation, with the aim of pursuing compliance with the health and safety legislation In the event of there being an outbreak that is traced back to a water system under the control of the Association, the Chief Executive and Director of Asset Management should immediately be notified and will in turn notify the Scottish Housing Regulator in accordance with guidance on notifiable events. The Association will nominate a staff member to liaise with the Outbreak Committee and Health and Safety Executive as required. No staff member other than the Chief Executive will make contact with the press or undertake any interviews in relation to the incident. 13. Training All staff involved in legionella management will be provided with adequate training to allow them to undertake their duties effectively. Page 9 of 10

10 14. Policy review This policy will be reviewed every three years, or earlier if required by a change to legislation. Right to complain In the event you are not satisfied with the service you have received, please contact the Association for a copy of the Complaints Policy. This can also be viewed on Langstane Housing Association s website Equality and diversity The Langstane Group / Langstane Housing Association is committed to promoting equality and diversity across all areas of work. Discrimination or harassment of any kind is not tolerated. If you would like this document sent to you in large print, please contact Support Services on Page 10 of 10